I make my client's aware that most criminal investigations are certain to be followed by civil action on the subject of the investigation. Moreover, entering a guilty plea to a charge of tax evasion, by law stops a taxpayer from later contesting the issue of civil fraud, however, a plea of nolo contendere does not. For this reason, the government rarely accepts pleas of nolo contendere under these circumstances. I also counsel my client's that receiving a grant of criminal immunity for testifying against another taxpayer will usually not function as a grant of civil immunity under the same plea agreement.
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